Compliance / Regulatory Costs Definition, methodology, practical experiences
SUSTAINABLE COMPLIANCE METHODOLOGY
Transcript of SUSTAINABLE COMPLIANCE METHODOLOGY
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Improving Workers’ Lives Worldwide
The SCI was developed by FLA, an organization of
colleges and universities, civil society organizations,
and companies that are committed to protecting
the rights of workers around the world. This
methodology was developed directly in response to
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Why do we need the SCI?Since 2003, the FLA has conducted more than 800
independent social audits around the world, and
has analyzed the results to uncover what works (and
ZKDW�GRHVQ¶W��IRU�LPSURYLQJ�ODERU�SUDFWLFHV�DQG�conditions. We have found that the conventional
framework for conducting audits is useful for
remedying immediate problems in the workplace
and has, over time, succeeded in protecting workers
from the most egregious violations of labor ethics.
However, conventional audits do little to prevent
recurring violations or drive sustainable and
progressive improvements in working conditions.
Audits typically follow a “checklist” methodology,
meaning that auditors check for the presence or
DEVHQFH�RI�VSHFL¿F�FRQGLWLRQV�DQG�SUDFWLFHV�VSHOOHG�out in a code of conduct. Companies then work with
manufacturers to resolve code violations, such as
improving lighting, replacing abusive supervisors, or
providing safety equipment.
The problem with this approach is that these
³¿[HV´�GRQ¶W�KROG��,Q�WLPH��WKH�OLJKWLQJ�DQG�VDIHW\�HTXLSPHQW�ZHDUV�RXW�DQG�LVQ¶W�UHSODFHG��RU�DQRWKHU�abusive supervisor is hired. Because the underlying
SROLFLHV�DQG�SUDFWLFHV�DUHQ¶W�DGGUHVVHG��WKH�IDFWRU\¶V�QH[W�DXGLW�RIWHQ�XQFRYHUV�YHU\�VLPLODU�SUREOHPV��
,Q�HIIHFW��WKHVH�³FDWFK�DQG�¿[´�DXGLWV�DGGUHVV�WKH�symptoms of bad labor practices, without addressing
WKH�XQGHUO\LQJ�ÀDZHG�SUDFWLFHV�WKHPVHOYHV��)XUWKHUPRUH��NQRZLQJ�H[DFWO\�ZKDW�³UHG�ÀDJV´�auditors are looking for makes it relatively easy for
factories to implement the letter, but not the spirit,
of ethical codes.
7KH�6&,�LV�GHVLJQHG�WR�PRYH�WKH�¿HOG�RI�VRFLDO�compliance beyond cat-and-mouse games and
EDQG�DLG�¿[HV��(DFK�6&,�DVVHVVPHQW�UHVXOWV�LQ�sustained improvements in employment systems
DQG�SUDFWLFHV�VR�WKDW�H[LVWLQJ�FRGH�YLRODWLRQV� are addressed and future code violations are
minimized. This system of assessment will help
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�� %\�JDXJLQJ�XVXDO�DQG�QRUPDO�ZRUNLQJ�FRQGLWLRQV�rather than a snapshot on a particular day, the
SCI reduces the likelihood of cheating the system
or masking ongoing problems.
SUSTAINABLE COMPLIANCE METHODOLOGYThe Fair Labor Association’s (FLA) Sustainable Compliance methodology (SCI) advances workers’ rights by e!ecting progressive and sustained improvements in employment practices and working conditions.
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�� 7KH�6&,�XQFRYHUV�URRW�FDXVHV�RI�SUREOHPV�DQG�provides systemic, sustainable solutions so that
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�� 7KH�6&,�PHDVXUHV�DQG�WUDFNV�LPSURYHPHQWV�LQ� working conditions, thus providing useful
information to conscientious buyers and civil
society organizations. It also creates incentives
for companies to continually improve their
labor practices rather than just meeting basic
requirements.
How it Works
The SCI departs from conventional auditing approaches in two main ways:
1. It looks at code violations in the context of a holistic picture of the factory’s employment practices. By relating code violations to weaknesses in underlying policies, practices or governance, the SCI shows how violations FDQ�EH�¿[HG�LQ�D�ODVWLQJ�ZD\�
2. It requires companies and manufacturers to collaborate to show progressive improvement on key aspects of labor management. The focus on tracking improvements in factory functions reduces the incentive to mask or gloss over underlying problems.
To understand how this works, compare it to how your doctor might handle a wellness visit:
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�� 7KH�6&,�PDNHV�PRQLWRULQJ�DQG�DVVHVVLQJ�easier for all stakeholders by providing
standardized assessments and scores that allow
for benchmarking, comparison and tracking
progress (either for individual factories or for an
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�� 7KH�6&,�HPSKDVL]HV�ZRUNHU�IULHQGO\�management systems and greater participation
of workers in the formulation, implementation
and review of policies and will be a driver
towards greater awareness and inclusion.
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SCI Tools7KH�6&,�V\VWHP�KDV�WKUHH�PDLQ�FRPSRQHQWV�
1. An assessment protocol based on how well a factory performs crucial employment functions such as recruitment,
hiring, determining and paying wages,
setting hours of work, and addressing worker
grievances. SCI assessors are trained to look
at all aspects of how a factory handles these
functions, such as whether or not there is a set
policy, how well that policy is communicated to
workers and line managers, how consistently it
is implemented, and how it impacts workers.
2. Standardized reporting tools that can be
used to generate scores on each employment
function. These are essential for benchmarking,
comparing and tracking progress over time.
3. A tool-chest of capacity building resources�WR�KHOS�)/$�DI¿OLDWHV�LPSURYH�WKHLU�internal monitoring systems and effect sustained
improvements in their supply chains. This
includes self-assessment protocols, online and
in-person trainings, and sample documents and
templates to facilitate remediation.
The SCI AssessmentAn SCI assessment is both deeper and broader
than a conventional audit. It has the following
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�� 7KH�DVVHVVRUV�UHYLHZ�IDFWRU\�VHOI�DVVHVVPHQWV�and other management documents and confer
with local civil society organizations to identify
potential problem areas.
�� 7KH�DVVHVVRUV�PDS�WKH�IDFWRU\�VWUXFWXUH�DQG�ZRUNÀRZ�IRU�HDFK�HPSOR\PHQW�IXQFWLRQ��This tells the assessor what to look for and
ZKRP�WR�DVN�DERXW�LPSOHPHQWDWLRQ�RI�VSHFL¿F�components.
�� 7KH�DVVHVVRUV�WKHQ�FROOHFW�GDWD�WKURXJK�WDUJHWHG�management interviews and visual observation
of factory conditions.
�� $VVHVVRUV�FRQGXFW�RQ��DQG�RII�VLWH�LQWHUYLHZV�and survey factory workers to understand what
is actually happening in the workplace.
�� 7KH�LQIRUPDWLRQ�LV�HQWHUHG�LQWR�D�VWDQGDUGL]HG�reporting tool to generate factory scores, which
DUH�WKHQ�WUDQVODWHG�LQWR�¿QGLQJV�DQG�XVHG�WR�VHW�action priorities. These reports are published at
www.fairlabor.org/transparency.
How the SCI will be used(YHU\�\HDU��WKH�)/$�DVVHVVHV�KXQGUHGV�RI�IDFWRULHV�and makes the results available online. Starting in
2012, the FLA will use the SCI methodology for all of
these independent assessments. These assessments
will help brands and manufacturers to identify
priority areas for improvement. The FLA will also
conduct follow-up assessments on a sub-sample of
these factories to note how these changes are taking
hold.
0DQ\�)/$�DI¿OLDWHV�DOVR�KDYH�FRPSUHKHQVLYH�internal monitoring systems to track social
compliance across their supply chains. The FLA
LV�HQFRXUDJLQJ�DOO�RXU�DI¿OLDWHV�WR�DGRSW�WKH�6&,�methodology for their internal compliance function
DQG�ZLOO�IDFLOLWDWH�WKLV�DGRSWLRQ�WKURXJK�DQ�HI¿FLHQW�web platform and customized tools and protocols.
As more and more leading companies and brands
DGRSW�WKLV�PHWKRGRORJ\��LWV�EHQH¿WV�ZLOO�UHDFK�PRUH�factories and more workers.
FLA stakeholders believe that the impact of the SCI
PHWKRGRORJ\�ZLOO�H[WHQG�EH\RQG�WKH�$VVRFLDWLRQ��,Q�time, we hope that the SCI will become the industry
standard for monitoring social compliance and its
principles will be applied in other monitoring and
compliance systems. We believe that the social
compliance industry needs to be transformed to
better serve the interests of workers in globally
integrated supply chains, and the SCI is a big step in
that direction.